The California Supreme Court affirmed a decision of the court of appeal. The court held that a plaintiff who had previously been declared a vexatious litigant and who was subject to a prefiling order was not barred from prosecuting an action on his own after counsel who filed the action withdrew.
In 2002, attorney Joseph Shalant was declared a vexatious litigant within the meaning of Code Civ. Proc. §391. The trial court entered a “prefiling order,” pursuant to §391.7, barring Shalant “from filing any new litigation” in propria persona in a California court without leave of the court’s presiding judge.
